PA EV Rate Design Working Group Submits Final Recommendations To PUC

On March 29, 2023, the Electric Vehicle Rate Design Working Group filed its recommendations to the Pennsylvania Public Utility Commission (click here to view the document). The working group was established by an order of the PUC. The purpose of which was for stakeholder feedback on how the regulatory body should design rate structures in the emerging electric vehicle market.

The PPA represented the fuels industry on the working group in conjunction with Giant Eagle, Glassmere Fuel Services, Onvo, Sheetz, and Wawa. Other stakeholders included the state’s utility companies, several environmental organizations, and representatives from the EV charging industry. PPA’s goal in the process was to represent the interests of member companies who are (or at some point would be) interested in entering the EV Charging retail space. The primary comments presented by our group included:

  1. Opposition to electric utilities being able subsidize the buildout of the EV charging networks utilizing general rate payer assessments.
  2. Opposition to public utilities of owning or operating their own retail charging stations.
  3. Support of the creation of rate structure that would provide convenience stores and other retailers a level playing field in the entry to the EV charging business.

Click here to view the original letter submitted by the PPA. The primary points made by the PPA and fuel retailers were incorporated into the final working document.

For example, in terms of the market entry issue, some provisions of the report reference the PPA group recommendation that utilities should be required to provide alternate rate structures (volumetric) that would allow businesses to pay for electricity based on actual use of consumers charging at the retail site, as opposed to a monthly flat demand charge. The PPA group comments also included a call for a uniform rate policy on electric wholesalers to EV charger retailers that would provide for fair competition.

Most of the rest of report discussed pathways for a rate structure that recognizes the changing landscape of electric usage. For example, the fact the most EV owners charge at their homes overnight. That raised the question as to whether a rate should be developed for those customers (and would that require separate meters). One recommendation submitted by PECO (that raises a red flag from PPA’s perspective) suggests that the Commission establish a policy structure that would deal with the operation of utility owned and operated EV charger facilities if Pennsylvania law would change to allow for that.

This is a signal that PECO will likely resurrect its effort in the legislature to get a bill passed that would do PPA (and its allies including API and NFIB) vigorously opposed the PECO legislation (SB 435 Mensh) last session. That bill was stopped last year (read more here) and has not been reintroduced to date in the current legislative session.

The recommendations of the working group are not binding on the PUC Commissioner, but it is an important step for our industry to be on record. The PPA would like to thank NATSO and Charge Ahead Partnership for their technical assistance on this project. Our association will be carefully monitoring the Commission’s next steps.